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Published Binding Rulings

The Commissioner publishes binding rulings when considered necessary, for different reasons and in different circumstances. These rulings are divided as follows:

  • Binding Class Rulings (BCRs) 
    BCRs are issued on application only in favour of a specified class of taxpayers.
    They determine how SARS interpret and apply the relevant tax law’s provisions in relation to a proposed transaction.

A binding class ruling is published by consent of the applicant to which it has been issued. It has a binding effect between SARS and the applicant and class members only, and is published for general information. It does not constitute a practice prevailing. A third party may not rely upon a binding ruling under any circumstances.  In addition, published rulings may not be cited in any dispute with SARS, other than a dispute involving the applicant or any co-applicant(s) identified therein.

  • Binding Private Rulings (BPRs)   
    BPRs are issued in favour of an applicant (or applicants) and cannot be applied in general by other taxpayers.
    They determine how SARS interpret and apply the relevant tax law’s provisions in relation to a proposed transaction.

A binding private ruling is published by consent of the applicant to which it has been issued. It has a binding effect between SARS and the applicant only, and is published for general information. It does not constitute a practice prevailing. A third party may not rely upon a binding ruling under any circumstances.  In addition, published rulings may not be cited in any dispute with SARS, other than a dispute involving the applicant or any co-applicant(s) identified therein.

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